# EPA Registration Number 74530-40

# ISB'S Front-end PRIA Completeness Screen Draft 3; 10/25107**---~~**

# ..----+--- EPA Receipt Date: 

# MAY 2')**~,'** tJ L U'. _. 

## EPA Reg. Number:

# 1-t(~3()-t(,J _r" •• 

## Check List Item Yes, No 

## NIA I flu, 

## lhe PRIA Fee been Paid; is a copyofthe check or 

# )( ruy.gov rcccipt 

## included in the Submission Package?

, 

## Is an Application Form (EPA Form 8570-1) Included in the 

# X

2 Suhll1iss'ion Package, is it completely filled out and signed including package type? 

# -_._---- Is a Confidential StatementofFormula (EPA Form 8570- 

# X 3 29) Il1dudcd in the SubmissionPackage, is 

## it completely 

## filled (lut and signed (boxes 1-21)?
4 

## Is a Formulator's Exemption Statement(EPA Fonn 8570- 

# X 27) Included in the Submission Package?



# --

# , J

## s u Certification with Respectto Citation ofData (EPA 

# X Form gS70-34) Included in the SubmissionPackage? 

# _. 

# --- ..**~-----~.**

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## Is a I)ata Matrix (EPA FOIm 8570-35) Included in the 

# X Submission Package?

# f

# X 7 Is u Label Included in the SubmissionPackage? 

## X



## ---- Arc Data Included inthe Submission Package? 

# X <) 

## Is the Submission anAmendment? 

## '---_L_ 

# >< II

# ()JJv;;j. 

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# 11)

DocumentProcessing Desk (AMEND) Office ofPesticide Programs (7504P) 

# u.s. Environmental Protection Agency One Potomac Yard

- South Building 

## 2777 S. Crystal Drive Arlington, V A 22202 Attention: Ms. Venus Eagle PM #1 

# HELm RGRO US, INC. 8275Tournament Drive. Suite 340 Memphis, Tennessee 38125 Phone: [901)312-1525 Fax: (901)312-1535 lWJW.helmagro.com



## 12·09·2010



## RE: CANCELLATION OF REGISTRATIONS DearMs. Eagle: With this letter, Helm Agro US, INC. would like to cancel the following registrations effective immediately. 

## Heloprid 2AG (EPA Reg. # 

## 74530·39) Heloprid 4 (EPA Reg. 

## # 74530·40) There arc no stocksnor have there been any sales ofthese products. Please do not hesitate to contactme ifmore information is needed or questions arise. I canbe reached at 90I-312-1525 oratl11wixson(i)bclmagro.com. Sincerely:

Dr. Marshall B. Wixson Ph.D. Manager Product Development Helm Agro US, Inc.,>.,'1100 

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## Or**Issu~lIec:** " &. EPA**R~g**. 

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## ",4' -i( PRO'l\'..v IJ.S,**ENVIRONMENTAI~** PROTECTION AGENCY 

### 74530-40**Ome~** (lrPesticide Programs TClm or Issuanec: Conditional**Regist,~tion** Division (1175051') 1200 PCnllsylvnnia Awnue NW Name ofPestieide Product: WashinglOlI, D,C. 20460 Heloprid 4 Insecticide 

### NOTICE OF PESTICIDE: .1L. Registration

_ Reregistration (lmder FIFI{A. as <lmended)
Name and Address orRcgistrallt (incl"de ZIP Code): Mr. Marshall 

### B. Wixson Helm Agro 

### US, Inc. 8295 Tournament Drive, Suite 310 Memphis, TN 

### 38125

Nole: Changes in labciing differing in subslance fmm that accepted in connection with this regisUlltion must bc submitlcd to and accepted by the Rcgistration Division priorto use orthe label in commerce. In <lnyeOlTespondencc on this product always referto the abovc EPA registl11tion**TIunlb~'T.** On thc basis orilironTI<lt;on furnished hy thc rcgistrant, the above namcd pesticide is herebyregistered/reregistered under the**F~"(lcral** Insecticide. Fungicide <Ind Rodenticide Act. I{egistratioll is in In)w<ly to be**~onstrued** as all**endors~ment** orrecommendation orthis product by the Agency, In ordcr 10protect health alld the cnvironment. th" Admillistrator. Oil his Illotion, may at any tinle suspend orcancel the registration (lra**p~'SticidL'** in aecordance with the Act. 'nlc aeceptullce or,my n<lme in connection with the rcgistnltion ora prodllet under this Act is IIOtlO be construed us gi'iing thc registrant a rightto exclusive
use orthcIlainc ortil its usc ir it**h~s** been eovcn::d hy others. This product is conditionally registered in accordance with FIFRA sec. 3(c)(7)(A). Once a pesticide is registered, however, it is not regarded as pennanentIy acceptable. Registration does not eliminate the need for continual reassessment ofpesticides. Ifthe Agency detennines that, at any time, additional data are required to maintain in effect an existing registration, the Agency will require submission ofsuch data under FIFRA section (3)(c)(2)(8). 

### I. Revise the EPA Rerristration Number to read, EPA Reg. No. "74530-40". Signature orApproving Orrieial: 

## I)".,

# J-0~M- ? cw:fc SEP 052008 Inscc(icidc-Roden(icide Branch Regislralion Division (7505P)



### EPA Form 8570-6

## Page Two 74530-40

2. Submittwo copies ofyour final printed label before you release the product for shipment. Ifthese conditions are not complied with, the registration will be subjectto cancellation in accordance with FIFRA section 6(e). Your release for shipment ofthe product constitute acceptance ofthese conditions. A stamped copy ofthe label is enclosed for your records. Ifyou have any questions regarding this notice contact Dani Daniel at 703 305-5409.

# HELOPRID 4 INSECTICIDE
For protection of cotton and pecans from certain insects and promoting enhanced plant health and yield ACTIVE INGREDIENT:



### Imidacloprid, 1-[(6-Chloro-3-pyridinyl)methyl]-N-nilro-2-imidazolidinimine
......................................_ ............................40.7% INERT INGREDIENTS:

......................................................,.............,........,..................................................__...................... 59.30/0 Contains 4.44 pounds of active ingredient per gallon. 

### Shakewell before using. EPA Reg. No. 74530- 

### NET CONTENTS: 1 gallon Manufactured for: EPA Est. No.

IFSWALLOWED:

IFONSKINOR CLOTHING:
IF INHALED: 

### Helm Agro US, INC. 8295 Tournament Drive Suite #310 Memphis, TN 38125 

# STOP
- Read the label before use KEEP OUT OF REACH OF CHILDREN CAUTIONICUIDADO FIRST AID

- Call a poison conlrol center or doclorimmedialely fortrealment advice.

- Have person sip a glass ofwaler if able 10 swallow

. • Do not induce vomiling unless told 10 do so by a poison conlrol center ordoctor.

- Do not give anything by moulh 10 an unconscious person. •Take offconlaminated clolhing.

- Rinse skin immedialely with plenty ofwalerfor 15 to 20 minutes.

- Call a poison control cenler or doclorfortrealmenl advice.

- Move person to fresh air. -If person is not brealhing, call 911 oran ambulance, then give artificial respiralion.

- Call a poison cOnlrol centeror doclorfor further Irealment advice. 

### 100.0%

IFINEYES:

- Hold eye open and rinse slowly and genllywith walerfor 15 to 20 minutes. Remove contacllenses, if present, after Ihe first 5 minules. then conlinue rinsing eye.

- Call a poison control cenleror doctorfor Ireatment advice. Have a produci container or label with you when calling a poison control center ordoctor, or going for treatment. Note To Physician: No specific anlidole is available. Treat Ihe palienl symplomatically.


# ACCEPTED**~Ef.,~ f~cide,**  under ide 

### and R,odentlcide 

### AD..

## ~~ for the pesticide RegUt.red

# un1' -/,",p- -" EPA Reg. NO<" 

## Y.JJrrLLr - 1 -

### PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS CAUTION Harmful jfswallowed, absorbed through skin, or inhaled. Avoid breafhing vapor orspray mist. Wash thoroughly with soap and waler after handling. Remove contaminated clothing and wash before reuse. Personal Protective Equipment (PPE): Some materialsthat are chemical resistantto this product are listed below. More options can be obtained by following the instructions for Category C on an EPA chemical-resistance category selection chart. Applicators and other handlers mustwear.

• Long-sleeved shirt and long pants • Chemical·resistant gloves made ofany waterproof malerial such as, nitrile rubber, butyl rubber, neoprene rubber, barrIer laminate, polyethylene, polyvinyl chloride (PVC) orvlton. • Shoes plus socks Follow manufacturer's instructions forcleaning/maintaining personal protective equipment (PPE). Ifnosuch instructions forwashables, use detergent and hotwater. Keep and wash PPE separately from other laundry. ENGINEERING CONTROLS STATEMENT When handlers use closed systems, enclosed cabs, or aircraft in a mannerthat meets the requirements listed in theWorker Protection Standard 0NPS) for agricultural pesticides [40 CFR 170.240 (d){4-6)], the handler PPE requirements may be reduced or modified as specified in the WPS.
USER SAFETY

RECOMMENDATIONS Usersshould: Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Remove Personal Protective Equipment immediately after handling this product. Wash the outside ofgloves before removing. As soon as possible, wash thoroughlyand change into clean clothing.

ENVIRONMENTAL HAZARDS Do not apply directly to wafer, areas where surface water is present orto intertidal areas below the mean high water mark Do not contaminate waterwhen disposing ofequipment washwaters. This product is highly toxic to bees exposed to direct treatment or residues on blooming crops orweeds. Do not apply this product or allow it to driftto blooming crops orweeds if bees are visiting the treatment area. This product is toxic to wildlife and highly toxic to aquatic invertebrates. This chemical demonstrates the properties and characteristics associated with chemicals detected in ground water. The use ofthis chemical in areas where soils are permeable, particularly where the watertable is shaDow, may result in groundwatercontamination.
TAKE THE FOLLOWING PRECAUTIONSWHEN MIXING AND APPLYING IN THE VICINITY OF AQUATIC AREAS SUCH AS LAKES; RESERVOIRS; RIVERS; PERMANENT STREAMS, MARSHES OR NATURAL PONDS; ESTUARIES AND COMMERCIAL FISH FARM PONDS. Spray Drift Management The interaction of many equipment and weather related factors determine the potential for spray drift. The applicator is responsible for considering all ofthese factors when making application decisions. Avoiding spray drift is the responsibility ofthe applicator. Mixingand Loading To avoid potential contaminailon ofgroundwater, the use ofa properly designed and maintained containment pad for mixing and loading of any pesticide into application equipment is recommended. Ifcontainment pad is not used, maintain a minimum distance of25 feet between mixing and loading areas and potential surtace to groundwaterconduits such as field sumps, uncased well head, sinkholes orfield drains. ForAerial Applications The spray boom should be mounted on the aircraft so as to minimize drift caused bywing lipvortices. The minimum practical boom length should be used, and must not exceed 75% ofthe wing span or rotor diameter.



### . 2 .

### Importanceof Droplet Size An important factor influencing drift is droplet size. Small droplets « 

### t50· 200 microns) driftto a greaterextent than large droplets. Within typical equipment specifications, make applications to deliverthe largest droplet spectrum that provides sufficient control and coverage. Formation ofvery small droplets may be minimized by appropriate nozzle selection, by orienting nozzles away from the air stream as much as possible and by avoiding excessive spray boom pressure. Release the spray at the lowest possible height consistentwith good pest control and flight safety. Do not make applications more than 10feet above the crop canopy. Wind Speed Restrictions Drift potential increases at wind speeds of less than 3 mph (due to inversion potential) or more than 10 mph. However, many factors, including droplet size, canopy and equipmem specifications determine drift potential at any given wind speed. Do not apply when winds are greater than t5 mph and avoid gusty and windless conditions. Risk of exposure to sensitive aquatic areas can be reduced by avoiding applications when wind direction is toward the aquatic area. Restrictions DuringTemperature Inversions Do not make aerial oraround applications during temperature inversions. Drift potential is high during temperature inversions. Temperature inversions restrict vertical air mixing, which causes small suspended droplets to remain close to the ground and move laterally in a concentrated cloud. Temperature inversions are characterized by increasing temperature with altitude and are common on nights with limited cloud coverand light to no wind. They begin to form as the sun sets and often continue into 1he morning. Their presence can be indicated by ground fog; however iffog is not present, inversions can also be identified by the movement ofsmoke from a ground source. Smoke that layers and moves laterally in aconcentrated cloud (underlow wind conditions) indicates an inversion, while smoke that moves upward and rapidlydissipates indicates good vertical mixing. Airblast (AirAssist) forTree Cropsand Vineyards Airblast sprayerscarry droplets into the canopy oftrees/vines via a radially, or laterally directed air stream. Follow the specific drift management practices below: • Adjust deflectors and aiming devices sothat spray is only directed into the canopy; • Block off upward pointed nozzles when there is no overhanging canopy; • Use only enough airvolume to penetrate the canopy and provide good coverage; • Do not allow the spray to go beyond the edge ofthe cultivated area (i.e., turn offsprayerwhen turning at end rows); • Only spray inward, toward the orchard orvineyard, for applications to the outside rows. No-SprayZone Requirementsfor FoliarApplications Do notapply by ground within 25 feet, or by airwithin 150feet of lakes; reservoirs; rivers; permanent streams, marshes or natural ponds; estuaries and commercial fish farm ponds. RunoffManagement Do not cultivate within 10feet ofthe aquatic areas to allow growth ofavegetative filter strip. When used on erodible soils, employ the best management practices for minimizing runoff. Consult your local Natural Resources Conservation Service for instructions in your use area. Endangered Species Notice Underthe Endangered SpeciesAct, it is a Federal Offenseto use any pesticide in a mannerthat results in the death ofamemberofan endangered species. Consult your local county bulletin, County Extension Agent, or Pesticide State Lead Agency for information conceming endangered species in yourarea. Resistance Management Some insects are known to develop resistance to insecticides after repeated use. 

### As with any insecticide, the use ofthis product should conform to resistance management strategies established forthe use area. HELOPRID 4 contains a Group 4A insecticide. Insect biotypes with acquired or inherenttolerance to Group 4A insecticides may eventually dominate the insect population ifGroup4A insecticides are used repeatedly as the predominant method ofcontrol fortargeted species. The active ingredient in HELOPRID 4 is a memberof neonicotinoid chemical class. Avoid using a block of more than three consecutive applications of HELOPRID 4 and/orother Group 4A products having the same or similar mode ofaction. Following a neonicotinoid block oftreatments, SHARDA USA strongly encourages the rotation to ablock ofapplications with effective products ofa different mode ofaction before using additional applications of neonicotinoid products. Using a block rotation orwindowed approach, along with other IPM practices, is considered an effective use strategy for preventing or delaying an insect pest's ability to develop resistance to this class of chemistry. Foliarapplications of HELOPRID 4 orother Group 4A products from the neonicotinoid chemical class should notbe used on crops previouslytreated with along-residual, soil-applied product from the neonicotinoid chemical class. Other Group 4A neonicotinoid products used as foliar treatments include: TRIMAXTM PRO Insecticide, Actara, Assail, CALYPSO, Centric, Couraze, Intruder, LEVERAGE, Pasada and PROVADO. Other Group 4A neonicotinoid products used as soil treatment include: ADMIRE, Alias, Couraze and Platinum. Contact your local extension specialist, certified crop advisor and/or product manufacturerfor additional insect resistance management recommendations. Also, for more information on Insect Resistance Management (IRM), visit the Insecticide Resistance Action Committee (IRAG) on the web at hftpfflrac-onfine.org.


### - 3 -

## DIRECTIONS FOR USE It isa violation of Federal lawto usethis product ina mannerinconsistentwith its labeling. Do not apply this product in a way that will contact workers orother persons, either directly orthrough drift. Only protected handlers may be in the area during application. Forany requirements specific to your State orTribe, consultthe agency responsible for pesticide regulation. 

### AGRICULTURAL USE REQUIREMENTS

Use this product only in accordance with its 

### labeling and the Worker Protection Standard, 40 CFR part 170. This Standard contains requirements forthe protection ofagricultural workers on farms, forests, nUrseries, and greenhouses, and handlers ofagricultural pesticides. 1\ contains requirements fortraining, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), and restrlcted..entry interval. The requirements in this box only apply

### to uses ofthis productthat are covered by the Worker Protection Standard. Do notenter or allow worker entry into treated areas during the restricted entry interval (REI) of t2 hours. PPE required for earlyentry to treated areas that is permitted underthe Worker Protection Standard and that involves contact with anything that has been treated, such as plants, soil, orwater, is: Coveralls Chemical-resistant gloves made ofany waterproof material such as, nitrile rubber, butyl rubber, neoprene rubber, barrier laminate, polyethylene, polyvinyl chloride (PVC) orviton. Shoes plus socks


### STORAGE AND DISPOSAL Do not contaminate water, food, orfeed by storage or disposal. Pesticide Storageand Disposal: Store in a cool, dry place, out ofdirect sunlight, and in such a manneras to prevent cross contamination with other pesticides, fertilizers, food, and feed. Store in original container and outofthe reach ofchildren, preferably in a locked storage area. Handle and open container in a manner as to prevent spillage. Ifthe container is leaking, invert to prevent leakage. Ifcontainer is leaking or material spilled for any reason or cause, carefully dam up spilled material to prevent runoff. Refer to Precautionary Statements on label for hazards associated with the handling ofthis material. Do notwalk through spilled material. Absorb spilled material with absorbing type compounds and dispose ofas directed for pesticides below. In spill or leak incidents, keep unauthorized people away. 

### CONTAINER DISPOSAL STATEMENTS Nonerefillable Containers: Do not reuse or refill this container. Offer for recycling, ifavailable. Clean container promptly after emptying. Nonerefillable container equal to or less than 5 gallons: Triple rinse as follows: Empty the remaining contents into application equipment ora mix tank and drain for 

### 10 seconds afterthe flow begins to drip. Fill the container 

### %full with water and recap. Shake for 

### to seconds. Pour rinsate into application equipment or mix tank orstore rinsate for later use or disposal. Drain for 

### 10 seconds afterthe flow begins to drip. Repeat this procedure two more times.


### APPLICATION DIRECTIONS Do NotApply HELOPRID4 In Enclosed Structures Such As Greenhouses Or Planthouses. Apply HELOPRID 4 as adirected or broadcast foliar spray. Thorough coverage offoliage is necessary without runofffor optimum insecticidal efficacy. Use adequate sprayvolumes, properly calibrated application equipment and spray adiuvant if necessaryto obtain thorough coverage. Failure to provide adequate coverage and retention of HELOPRID 4on leaves and fruit may result in loss of insect control or delay in onset ofactivity. HELOPRID 4 may be applied with property calibrated ground oraerial application equipment. Minimum spray volumes unless othelWise specified on crop specific application rate sections are 

### to gallons/Acre by ground application and 5 gallons/Acre through aerial equipment. HELOPRID 4 may also be applied by ovemead chemigation (see additional CHEMIGATION DIRECTIONS FOR USE section below) ifallowed in crop specific Application Rate section. HELOPRID 4 use on crops grown for production oftrue seed intended for private or commercial planting is generally not recommended but may be allowed under State speCific supplemental labeling. 

### As with any insecticide, care must be taken to minimize exposure of HELOPRID 4 to honey bees and otherpollinators. Use of HELOPRID 4 on crops requiring bee pollination should 

### be avoided during bloom and a minimum of 

### 10 days priorto bloom. Additional information on HELOPRID 4 uses forthese crops and otherquestions may be obtained from the Cooperative Extension Service, PCAs, or consultants. Do not apply more than 0.5 Ibs. active ingredient per acre, per crop season, regardless offormulation or method ofapplication, unless specified within a crop-specific Application Rate section fora given crop.


### - 4 -MIXING INSTRUCTIONS HELOPRID 4 is a suspension concentrate (flowable) formulation that must be shaken well priorto measuring/mixing. The formulation is thixotropic and aftersitting for ashort time reverts to agel orthick paste consistency helping to prevent phase separation common to most "flowables". After moderate shaking the formulation thins to a relatively non-viscous liquid which pours and measures easilywith very few trapped air bubbles· anothercommon problem of most flowables.
HELOPRID 

### 4 has demonstrated easy mixingtblooming in waterwith varying degrees of hardness andtemperature. HELOPRID 

### 4 has demonstrated good mixing and compatibility with many fluid fertilizers without dilution with water. However, because fertilizers vary widely in quality and composition it is suggestedthat ajartest be performed (see Compatibility Note below) priorto full-scale mixing. To prepare the application mixture, add a portion ofthe required amount ofwaterto the tank and wUh agUation add HELOPRID 

### 4. Complete filling tank with balance ofwater needed. Maintain sufficient agitation during both mixing and application. HELOPRID 

### 4 may also be used with otherpesticides and/orfertilizersolutions. Please see Compatibility Note below.When tank mixtures of HELOPRID 4 and other pesticides are involved, prepare the tank mixture as instructed above and follow suggested Mixing Order below. Mixing Order When pesticide mixtures are needed, add wettable powders orwettable granules first, HELOPR1D 

### 4 and otherflowable (suspension concentrate) products second, and emulsifiable concentrates last. Ensure good agitation as each component is added. Do not add an additional component until the previous isthoroughly mixed. Ifafertilizer solution is added, a fertilizer/pesticide compatibility agent may be needed. Maintain constant agitation during both mixing and applicationto ensure uniformity of spray mixture. CompatibilityNote Test compatibility ofthe intended mixture before adding HELOPR1D 

### 4 tothe spray or mix tank. Add proportionate amounts ofeach ingredient in the appropriate order, to apint orquartjar, cap, shake for 

### 5 minutes, and let set for 

### 5 minutes. Poor mixing orformation of precipitatesthat do not readily redisperse indicates an incompatible mixture that should not 

### be used. CHEM1GAT10N DIRECTIONS FOR USE Referto DIRECTIONS FOR USE section before proceeding with chemigation application. Types of Irrigation Systems Chemigation applications of HELOPRID 

### 4 may

### be madeto crops through overhead sprinklerchemigation systems ifspecified in crop-specific application sections. Do not apply HELOPRID 4 through any othertype of irrigation system. WaterVolume HELOPRID 4chemigation applications should 

### be made as concentrated as possible. Retention of HELOPRID 4 on target site of insect infestation is necessary for optimum activity. Chemigation of HELOPRID 

### 4 in water volumes exceeding 

### 0.1 inch/Acre is not recommended. UnifonnWater Distribution and System Calibration The irrigation system must provide uniform distribution oftreated water. Crop injury, lack ofeffectiveness, or illegal pesticide residues in the crop can result from non-uniform distribution oftreated water. The system must 

### be calibrated to uniformly applythe rates specified. Ifyou have questions about calibration, you should contact State Extension Service specialists, equipment manufacturers orother experts. Chemigation Monitoring A person knowledgeable of the chemigation system and responsible for its operation, or underthe supervision of the responsible person, shall shut the system down and make necessary adjustments should the need arise. Drift Do not apply when wind speed favors drift beyond the area intended fortreatment. Required System 

### Safety Devices The system must contain a functional check valve, vacuum reliefvalve, and low-pressure drain appropriately located on the irrigation pipelineto prevent water source contamination from backfiow. The pesticide injection pipeline must contain a functional, automatic, quickclosing check valve to prevent the flow offluid back toward the injection pump. The pesticide injection pipeline must also contain a functional, normally closed, solenoid-operated valve located on the intake side ofthe injection pump and connected to the system interlock to prevent fluid from being withdrawn from the supplytank when the irrigation system is eitherautomatically ormanually shut down. The system must contain functional interlocking controlsto automatically shut offthe pesticide injection pump when the water pump motor stops. The irrigation line orwaterpump must include a functional pressure switch which will stopthe water pump motorwhen the water pressure decreasestothe point where pesticide distribution is adversely affected. Systems must use a metering pump, such as a positive displacement injection pump (e.g., diaphragm pump) effectively designed and constructed of materials that are compatible with pesticides and capable ofbeing fitted with a system interlock. UsingWaterfrom PublicWaterSystems Public water system means a system for the provision to the public ofpiped waterfor human consumption ifsuch system has at least 15 service connections or regularly serves an average ofat least 25 individuals dailyat least 60days out ofthe year. Chemigation systemsconnected to public water systems must contain afunctional, reduced-pressure zone, back flow preventer(RPZ) orthe functional equivalent in the watersupply line upstream from the point of pesticide introduction. Discharge the waterfrom apublic water system into a reservoirtank priorto pesticide introduction as an option to the (RPZ). There shall be acomplete physical break (airgap) betweenthe outlet end ofthe fill pipe and totop or overflow rim ofthe reservoirtank ofat least twice the inside diameter 

### - 5 -

### ofthe fill pipe. The pesticide injection pipeline mustcontain afunctional automatic quick-closing check valve to prevent the flow offluid back toward the injection. The pesticide injection pipeline mustcontain afunctional normallyclosed solenoid-operated valve located on the intake side ofthe injection pump and connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the irrigation system is either automatically or manually shut down. The system must contain functional interlocking controls to automatically shut offthe pesticide injection pump when the water pump motor stops orin cases where there is no waterpump, when the water pressure decreases to the point where pesticide distribuflon is adversely affected. Systems must use a metering pump such as a**pos~ive** 

### displacement injection pump (e.g. Diaphragm pump) effectively designed and constructed of materials that are compatible with pesticides and capable of being fitted with asystem interlock. 

### ROTATIONAL CROPS Treated areas may be replanted with any crop specified on an imidacloprid label, orany crop for which atolerance exists forthe active ingredient, as soon as practical following the last application. For crops not listed on an imidacloprid label, orfor crops for which no tolerances for the active inQredient have been established there is a 12 month plant back interval. IMMEDIATE PLANT-BACK All crops on this label plus the following crops not on this label: barley, canola, Christmas trees, corn (field, sweet and pop), cranberry, Globe artichoke, grape, mustard seed, okra, potato, rapeseed, strawberry, sorghum,sunflower,sugar beet,tobacco,watercress, and wheat and all crops from the foHowing Crop Groups as recognized and defined by EPA. Crops contained within a particularcrop group are subjectto change. For information related to specificcrops please refer to the EPAwebsite (www.epa.qov)forlatestcropgroups. ROOT VEGETABLES
- crops ofcrop group 1 LEAFY GREEN VEGETABLES
- crops ofcrop group 4 HEAD & 

### STEM BRASSICAVEGETABLES
- crops ofcrop group 5 LEGUME VEGETABLES
- crops ofcrop group 6 including edible podded & 

### dried & 

### succulent shelled peas and beans FRUITING VEGETABLES
- crops ofcrop group 8 CURCURBIT VEGETABLES
- crops ofcrop group 9 CITRUS
- crops ofcrop group 10 POME FRUIT
- crops of 

### crop group 11 STONE FRUIT -crops ofcrop group 12 BUSHBERRYand CANEBERRY-cropsofcrop group 13 HERBS
- crops ofcrop subgroup t9A TROPICAL FRUIT
- Including: Acerola, Atemoya, Avocado, Birida, Black sapote, Canistel, Cherimoya, Custard apple, Feijoa, Llama, Jaboticaba, Guava, Longan, Lychee, mamey sapote, Mango, Papaya, Passionfruit, Persimmon, Pulasan, Rambutan, Sapodilla, Soursop, Spanish lime, Staraop·le, Starfrui\, Suaar-aocle, Wax ·ambu 30-DAY PLANT-BACK Cereals (including buckwheat, millet, oats, rice, rye, and triticale), safflower, soybean 1O-MONTH PLANT-BACK Onion and bulbveaetables 12-MONTH PLANT-BACK All othercrops 'Covercrops forsoil building or erosion control may be planted anytime, butdo not graze or harvestforfood orfeed.


### Application Instructions
- HELQPRID 4 Insecticide HELOPRID 4 may be applied with properly calibrated ground or aerial application equipment. Applyspecified rate peracre as a directed or broadcastspray to infested area at eartiestthreshOld fortarget pest, as population begins to develop. Thorough uniform coverage ofall plant parts is required to achieve optimum control. Scout fields and retreat ifneeded. Make multiple arlllications of HELOPRID 4 to promote plant health and yield. The lower rates can be used early season when pest pressures are low orwhen tank-mixing with othereffective products registered for target insect control. Degree ofcontrol orsuppression ofadditional labeled pests will be determined, in part, by the stage ofpest development at application and infestation level ofthose pests. HELOPRID 4 provides optimal performance against early instar and early nymphal stages of insects as well as bollwormibudworm eggs. Applications made with less than 5 gallons per acre may result in slower activity and/or less overall control from a single application than an application made with highergallonages. The addition ofan organosilicone-based spray adjuvant is recommended for applications targeting aphids and whiteflies. Regardless offormulation or method ofapplication, apply no more than 0.5 Ib active ingredient of imidacloprid per acre perseason, including seed treatment, soil and foliar uses. 

### - 6 -COTTON

### v Pests Controlled Rate Auid Ounces/Acre Cotton aphid Cotton fleahopper 

### 0.9-1.8 Bandedwinged whitefly Plant bugs (excludes Lygus hesperus) Green stink bug Southem green stink bug Boliworm/Budworm (ovicidal effect)

Pests Suppressed Lygus bug (Lygus hesperus)Whiteflies (other 

### 1.35-1.8 than bandedwinged whitefly) Notes and Restrictions Pre-Harvest Interval (PHI): 14 days Minimum interval between applications: 7 days Maximum HELOPRID 4 allowed perseason: 8.9 fluid ounces/Acre (0.3t Ib AliA) Do not graze treated fields after any application of HELOPRID 4. 11 Use not oermitted in California unless otherwise directed bv suoplementallabelinq. Tank Mix Rates Pests Controlled(In HELOPRID 4 Bidrili!!l8* Rate AdditionTo Pests Listed Above) Rate Auid Fluid Ounces/Acre Ounces/Acre Forearlyseason control of: 

### 0.9-1.35 

### 1.6-3.2 Thrips For midto late season control of: 

### 0.9-1.35 4.0- 8.0 Plantbugs Stink bugs (including Brown stink bug) GrasshoppersSaltmarsh caterpillar Cotton leafperforator

Notes and Restrictions On addition to Notesand Restrictions listed above} * Referto the Bidrin®8 product label forspecific use recommendations; observe all restrictions and precautions thatappear on the label.

Pests Controlled Rate fluid ouncesJAcre Aphids (use higher rate for Black pecan aphid) 

### 1.3-2.6 Phylloxera Spittlebugs Notes and Restrictions Pre-Harvest Interval (PHI): 7 days Minimum interval between applications: 6 days Maximum HELOPRID 4 allowed per crop season: 10.1 fluid ouncesJAcre (0.35 Ib AliA) Do not apply pre-bloom or during bloom orwhen bees are actively foraging. 2J Use not permitted in California unless otherwise directed by supplemental labeling.



### - 7 -

# IMPORTANT: READBEFOREUSE Read the entire Directions lor Use, Conditions, Disclaimer 01 Warranties and Limitations of Liability before using this product. If terms are not acceptable, return the unopened product container at once, By uS'lng this product, user or buyer accepts the tollowing Conditions, Disclaimer 01 Warranties and UmHaflons 01 UabH'lty. CONDITIONS: The directions lor use 01 this product are believed to be adequate and must be tollowed carelully. However, it is impossible to eliminate all risks associated with the use 01 this product. Crop injury, ineltectiveness or other unintended consequences may result because 01 such lactors as weather conditions, presence 01 other materials, orthe manner 01 use or application, all 01 which are beyond the control ot Helm Agro US, !NC

.. All such risks shall be assumed by the user or buyer. DISCLAtMER OFWARRANTtES: TO THE EXTENT CONSISTENTWITH APPLICABLE LAW, HELM AGRO US, INC. MAKES NO OTHER WARRANTIES, EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. To the extent consistent with applicable law, no agent of Helm Agro US, INC. isauthorized to make any warranties beyond those contained herein 

### or to modify the warranties contained herein. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, HELM AGRO US, INC. DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OFTHIS PRODUCT. LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN CONTRACT, WARRANTY, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE PURCHASE PRICE PAID, OR AT HELM AGRO US, INC.'S ELECTION, THE REPLACEMENT OF PRODUCT.



### Net Contents: 1 Gallon Revised 9-4-08

ADMIRE, CALYPSO, LEVERAGE, PROVADQ and TRIMAX are registered trademarks ot Bayer CropScience. Actara, Centric, Cruiser and Platinum are trademarks ot a Syngenta Group Company. Assail and Intruder are registered trademarks ot Nippon Soda Company, LTD. Bidrin is a registered trademark of AMVAC Chemical Corporation. Alias and Pasada are trademarks ot Makhteshim Agan Couraze is a trademark ot Cheminova

Manufactured for: Helm Agro US, INC. 

### 8295 Tournament Drive Suite

### #310 Memphis, TN 

### 38125

- 8 -

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20'""'



## May28, 2008

OPP DecisionNumber: D-3941 19 EPAFile Symbol orRegistrationNumber: 74530-UN ProductName: HELOPRID 4 EPA Receipt Date: 23-May-2008 EPA CompanyNumber: 74530 CompanyName: HELMAGRO US, INC. MR. VOLKERHEIDE HELMAGROUS, INC. 8295 TOURNAMENTDRIVE, SUITE 3 I 0 MEMPHIS, TN 38125- OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES



## SUBJECT: Receipt ofRegistrationApplication Subject to Registration Service Fee DearRegistrant: The Office ofPesticide Programs has received your application and certification of payment. 

## Ifyou submitted data with this application, the results ofthe**PRN~86-5** 

## screen will 

## be communicated separately. Duringthe administrative screen, the Office ofPesticide Programs has determined that this Action is subject to a Pesticide Registration Service Fee as defined in thePesticideRegistration Improvement Act. TheAction has been identified as Action Code: R300 NEWPRODUCT;ME-TOOPRODUCT FASTTRACK; No additional payment is due at this time. Ifyou have any questions, please contact the Pesticide Registration Service Fee Ombudsman at (703) 305-6249. Sincerely,

# '~~~~ Front End Processing Staff Infonnation Technology& 

## Resources Management Division

# IFee for Servicel 

# {829722--

This package includes the following


# •• New Registration

.Amendment Studies? Fee Waiver? volpay 

# % Reduction: __ for Division 

# AD ·:BPPD

c· 

# RD Risk Mgr. Receipt No. 

# s-I 829722 EPA File Symbol/Reg. No. 

# I 74530-UN Pin-Punch Date: 

# I 5/23/2008 

# D This item is NOT subject to FFS action. Parent/Child Decisions: Requested: 

# I'K 3DO 

# Granted: 

# IIUD i) 

# Amount Due: 

# $ 1,3DV 

# L __________ L _________ -----' 

# X**Inert~** for Intended Use Uncleared Inert

# i~ Product Reviewer: / ell.{

# ~pLc. Date: 

# s/zr/uv
Remarks: 

# !tlt//v kld"'P, fro

# t'.d~e/15**~ 1~t/;P0.J'**  

# jl**LJ~,b:/**YPI 

# J

# h'/rp

### u.s. Environmental 

### Document No. 

### 052108 Document 

### Date 

### 05/21/08 

### May 21, 2008

Amount 

### 1,300.00

REORDER FORM NO, 802 LB1 (1 PART)



# PAY TOntE ORDER 

# " HELM AGRO US INC 8295 TOURNAMENT DRiVE, SUITE 310 MEMPHIS, TN 38125



### •••• ONE THOUSAND THREE HUNDREDAND 

### 01100 U.S. Environmental Protection Agency 

### Check No 4340

Discount 

### 0.00

Total

RRST TENNESSEE BANK 26-2/840

DATE 

### May 21,2008**II'OO~3~Oll'** 

# 004340

NetAmount 

### 1,300.00

1,300.00



# 004340

AMOUNT 

### *******1,300.00PrintForm PI

... o ,.. dftUitructiD_ on 'iU'60I..fore CDm 

# "" form. 

# '0 ApD/oved. OMB No. 207 ,·2B· United States 

# El Registration OPP Identifier Number 

# &EPA Environmental Protection Agency Amendment Washington, DC 20460 

## Other Application for Pesticide
- Section I 1. Compony/Product Number 2. EPA Product Menagel 3. Proposed Clessificetion 

### 74530· 

# uAi LaRocca 

# o None 

# o Restrict&d 4. Company/Product (Namo) PM' Heloprid 4 13 

# 5. Nama and Addross ofApplicant /lncludu ZIP Code/ 

### 6. Expedited Reveiw. In accordance with FIFAA Section 3(cJ(3) Helm Agro US, INC. (bJ(ij, my product is similar or identical in composition and labeling 

### 8295 TournamentDrive Suite #310 to: Memphis,TN 

### 38125 EPA Reg. No. 

# o Chl1ck ifthfs fs a newadd,ess Product Name 

## Section· II 

# 0 Amandment

- Explein below. 

# 0 Final printed labels in ropsonse to Agency lettol dated 

# 0 Resubmission in response to Agency lettel doted 

# 0 "Me Too" Applicetion. 

# 0 Notification

- Explain below. 

# lj Other

- Exploin below. Explanation: Use additienal pagelsl ifnecessary. (For seclion Iand Soction ILl

This is a REPACK


## Section· III t. Moterial Thl. Product Will Be Pockaged In: Chlld·Resistant Pockaging Unit Packaging Wator Solublo Packaging 2. Typo of Containor

# ~y"**~Yo.** 

# 5l y"

# ~M'''J X No X No 

# if.xt X Plestic Gloss



### .. Certification must If "Yes" No. por If "Yos· No. per Paper Unit Packaging wgt. container Package wgt container Other (Specifyl 

### be submitted 1 3. location ofNet Contants lnformotion 4. Slu(s) Rotoll Containor 

# 15. location of lebel Directions On Label

## ~ Lobol 

# o Container 

### 1, 2.5, 30 gallon

# ~ On Labeling accompaning product 6. Monnor in Which label is Affixod to P,oduct 

# § lithogreph 

# 0 Other Paparp;uod Stenci od

### Section 

# . IV I. ContoCt Point /Complote itoms directly below fo, identification ofindividual to btl centllcrod, ifntlcosslJf'(, to P'OCflSS this application.) Name Titla Telephone No. (Include Araa Cooel MarshalI 

### B. Wixson Manager Product Development 

### 901-312-1525 Certification 6.'o)att> Applicetion Icertily that the statements I have mode on this fOlm and 011 attachments thoreto oro true, accurate 000 con.p1f.te. R..tcaivlKl I acknowledge that any knowlinglly tels6 ormi:deoolng statomant mey bo punishablo by fino orimprisonment or (Stamped) both under epplicoble low. 2. Signeturo 3. TItle 

# p7 Manager Product Development 4. Typed Nama S.Oete 

### Marshall 

## B. Wixson 5-20-08



# . . . 

## .. 

# • . 

# .-

. . EPA Form 6570 1 IRev. 3 941 PrevIOus edItIons are obsolete• White EPA Fila CODV (onam. II Yellow App

# HELm**~** 

# .GRO US, INC.

Document Processing Desk (AMEND) Office ofPesticide Programs (7504P) U.S. Environmental Protection Agency One Potomac Yard

- South Building 2777 S. Crystal Drive Arlington, V A 22202 8295 Tournament Drive, Suite 310 Memphis, Tennessee 38125 Phone: (9011312.1525 Fax: [901 J312·1535



### Attention: Mr. George LaRocca. PM

# T~**~7**
RE: HELOPRID 4**~** 

## REPACK SUBMISSION

DearMr. LaRocca: 5-21-08



# qM' Please find encloyedthe following in support oftheregistration ofHELOPRID 4, EPA symbol 74530-. Theproduct is a repack of

1. Application for registration ofHELOPRID 4, EPA Form 8570-1 2. Confidential Statement ofFormula (CSF), EPAForm 8570-4 3. Formulator Exemption Statement, EPA Form 8570-27 4. Five copies ofproposed labeling and a copy on CD in .pdf 5. Copy ofCheck for fee ofRepack under PRIA II The label language is based onthe most recently approved label from

We would appreciate and EXPEDITEDreview ofthis submission. Please do nothesitate to contact me 

## ifmore information is needed or questions arise. I can be reached at 901-312-1525 or at mwixson@helmagro.com. Sincerely: 

# ft-;7 Marsl1a11 B. Wixson Ph.D. Manager Product Development Helm Agro US, Inc.Form approved. OMS No. 2070-0060, 2070-0057, 2070-01 07, 2070-0122, 2070-0164. 

# ,s,EPA
Uniled States Environmental Protection Agency Washinglon, DC 20460 

### Formulator's Exemption Statement (40 CFR 152.85)
Applicant's Name and Address EPA File Sym7e9istralion Number 

### Helm Agro US, INC. 74530- 

### U. 8295 TournamentDrive Suite #3 10 Producl Name 

### Memphis, TN 38125 Heloprid 4
Dale ofConfidenJial Slatement of Formula (EPA Form 8570-4) 

### 05/21/2008 As an authorized representative ofthe applicant for registration oflhe prodvct identified above, I certify thaI: (1) This producl conlains Ihe following active ingredient(s}: 

### Imidacloprid

(2) Ofthese, each active ingredient listed in paragraph (4) is present solely as Ihe result ofthe use of Ihal aclive ingredient in the manufacturing, formulation or repackaging anolher producl which conlains that active ingredient which is regislered under FIFRA Section 3, is purchased by us from anolher person and meets the requiremenls of40 CFR seclion 158_50(e}(2} or (3). (3) Indicale by checking (A) or (8) belowwhich paragraph applies: 71 {A} An accurale ConfidenJial Slatement of Formula (EPA FORM 8570-4) forthe above identified product is attached 10 Ihis statemenl. Thai formula statement indicates, by company name, registration number, and product name, the source ofthe active ingredienl{s) listed in paragraph (1). OR 

### ""1 (S) The Confidenliat $talemenl of Formula (CSF){EPA Form 8570-4) referenced above and on file with the EPA is complete, current, an accurale and conlains the information required on Ihe current CSF. (4) The following active ingredienls in IhiS producl qualify forthe formulalor's exemption.

Source Active Ingredient Product Name Registration Number 

### lmidacloprid

. Signature Name and Tille Date 

# /2---;/ Marshall Wixson/Manager PD II 

### 05/2112003



## --

- - EPA Form 8570 27 {Rev. 06 2004} 

## - COpy 1 EPf Copy 2 - Aoplicant copy

## Pages 19 contains the product confidential statement of formula and is not included in this copy